Scott E. Mollen, a partner at Herrick, Feinstein, analyzes recent decisions, including one where the Attorney General's claims of appraisal fraud were held not to be barred by HOLA, FIRREA or OTS regulations.
September 15, 2010 at 12:00 AM
1 minute read
Attorney General’s Claims of Appraisal Fraud Not Barred by HOLA, FIRREA or OTS Regulations—General Business Law §349.
This appeal involved the issue of whether “regulations and guidelines implemented by the Office of Thrift Supervision (OTS) pursuant to the Home Owner’s Lending Act of 1933 (HOLA)…and the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA)…, preempt state regulations in the field of real estate appraisal.”
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